OSHA, as well as NFPA and IFC, permit a "weak roof-to-shell seam" as the means for emergency venting on an OUTSIDE ABOVE GROUND ATMOSPHERIC storage tank for flammable liquids. This method was vey common in the early days, but has since been replaced with engineered fire vents. This video does an excellent job demonstrating how a "weak roof-to-shell seam" works and why emergency responders MUST be aware of how a flammable liquid tank will vent when involved in a fire scenario. The video at the bottom of the page shows what happens when the "weak roof-to-shell seam" does NOT work as designed. This same video then demonstrates a proper "weak roof-to-shell seam" working and we should take notice of the distance this tank roof travels!

Over the past year or so we have come across several situations where facilities have replaced their flammable liquid storage tanks, which some are used as a “waste tank”. These “waste tanks” fall under EPA’s RCRA rule and apparently these tanks have to be “fully inspected” on a set frequency and when tanks sit directly on their foundation this causes some issues with a “full RCRA inspection”. So it seems that there may be a concerted effort to install new flammable waste tanks, as well as other flammable tanks, on legs so that the bottom of the tank can be visually inspected with ease. Now I am no RCRA expert, but this explanation does make sense; and I have contacted two other businesses where we have seen this and they too stated the same reasons. But each facility viewed these new tanks as a “Replacement in Kind” since the tanks were the same size, same materials of construction, same operations, same nozzle arrangement(s), etc. EXCEPT these new tanks are installed on legs, which CHANGES things considerably and an MOC should have been done. Here’s why…

Respondent operates a natural gas processing and fractionation facility. Respondent had maintenance activities performed on the Inlet Filter Separator (“Vessel”) on March 10, 2014 and March 11, 2014. The Respondent used a contractor to perform the routine maintenance on the vessel, specifically, to replace filters. The Vessel was flooded with water overnight on March 10, 2014, which cleaned residual hydrocarbons from the vessel. All of the High Point Vent Valves on the vessel were not opened prior to flooding the vessel with water. On the day of the incident, March 11, 2014, the Vessel was drained and the filters were removed. Upon returning from lunch, but before the arrival of the operator assigned to oversee the project, the contractors noted white smoke escaping from the vessel. In response to the smoke one of the four contractors sprayed water into the vessel. A pyrophoric reaction occurred inside the vessel, and the ensuing fire injured the four contractors. The fire was extinguished and the injured workers were transported to emergency medical treatment.

Respondent does business in the Commonwealth of Kentucky and operates a "stationary source”. Respondent has developed an RMProgram accidental release prevention program for the stationary source. The Respondent, at its stationary source has an RMProgram covered process, ammonia refrigeration, which stores or otherwise uses anhydrous ammonia, in an amount exceeding its applicable threshold of 10,000 pounds. Based on an RMProgram compliance monitoring investigation initiated on March 30, 2013, the EPA alleges that the Respondent violated the codified rules governing the CAA Chemical Accident Prevention Provisions, because Respondent did not adequately implement provisions of 40 CFR Part 68 when it:

The Edison Electric Institute (EEI), the Utility Line Clearance Coalition (ULCC), and the Tree Care Industry Association (TCIA) have negotiated a settlement with OSHA on the compliance dates for this new standard. CLICK HERE for the official agreement.

On Sept. 2, 2014, OSHA initiated an inspection of a petroleum refinery after a fire occurred in a heater at the facility, used to process crude oil. The refinery sustained some minor damage but no injuries were reported. OSHA initiated the investigation under its National Emphasis Program for Process Safety Management at refineries. Here is the breakdown of the citations:

Fixed bug where MARPLOT files could get out of sync when a user had a layer with objects in individual graphics mode, then switched the layer to common graphics mode and added an object. This bug would result in several error messages appearing in MARPLOT. The fix prevents this issue from happening to layers in 5.0.1, and it also fixes the problem on any out-of-sync layer (from 5.0) the next time an object is added to the layer.

Fixed bug where images for object and layer popup notes where not included in MPZ export files.

Fixed bug where taking screenshots did not work on the Lion operating system.

Fixed several other small bugs and made minor program improvements, primarily to the way files are imported.

Note: If you're upgrading to MARPLOT 5.0.1 from a previous version, follow the instructions on the download page to ensure that your data is transferred successfully to the new version.

In the world of process safety we have Safe Upper and Lower limits on a lot of common process parameters, such as pressures, levels, temperatures, etc. Flows on the other hand are quite often over looked as a critical process parameter and when your HHC/EHS is a non-conductive flammable liquid both FLOW and LEVEL must be addressed within the facility’s PSI and SOPs. This article will discuss how safe upper limit on flow and safe lower limit on level can play a huge roll in improving flammable liquid safety and quite possibly PSM/RMP compliance.

Not a trick question, but boy do we get “the look” when we ask the question just as it is written in 68.79 and .119(o). What does OSHA and EPA mean by certifying an audit? Who does this certification? Is this a formal exercise of certifying? Why did OSHA/EPA use this term in the standard? Here is my take…